Privacy Policy

Last Updated: March 14, 2026

Introduction

Welcome to Face Minds, a product of BynarTek ("we", "us", "our"). BynarTek is the data controller for personal data collected through Face Minds. We respect your privacy and are committed to protecting your personal data.

1. Information We Collect

1.1 Personal Information

Account Information: Email address, display name, and password (encrypted)
Profile Information: Profile photos and biographical information you add
Family Tree Data: Information about family members including names, dates, relationships, biographical details, and custom fields
Face Memory Data: Personal information you add to Face Memory profiles, including name, date of birth, contact details, events, stories, prompt responses, and photos
Photos: Images you upload for family members, Face Memory profiles, and face recognition

1.2 Automatically Collected Information

Device Information: Device type, operating system, and app version
Usage Data: App features you use and how you interact with the app
Performance Data: App crashes and performance metrics
Subscription Information: Your subscription tier, purchase history, and billing status (processed through RevenueCat)
Advertising Data (Free tier only): Device advertising identifiers, ad views, and interactions (collected by AdMob)

1.3 Face Recognition Data

Facial features extracted from photos for face recognition purposes
This data is processed locally and securely stored

2. How We Use Your Information

Service Provision: Creating and managing your family trees
Face Recognition: Identifying faces in photos to help organize memories
Account Management: Authenticating and managing your account
App Improvement: Analyzing usage to improve features and performance
Communication: Sending important updates about your account or app changes
Support: Providing customer support when requested

3. Data Storage and Security

All data is stored on secure servers with encryption
Photos are stored using industry-standard cloud storage solutions
Facial recognition data is encrypted and stored securely
End-to-end encryption for data transmission; secure authentication using JWT tokens; password encryption using bcrypt

4. User Responsibility for Shared Content

4.1 Scope of Data

This section applies to ALL personal data you upload to Face Minds, including family tree members, Face Memory profiles in any category, any person appearing in photos or events you create, and historical or deceased individuals.

4.2 Your Responsibility

You are solely responsible for all personal information, photos, and data you upload or share
You must have proper consent from any individuals whose personal information or photos you add
You must have legal authority to share information about any individuals
You assume all liability for any privacy violations or legal issues arising from content you upload
You will not use the App to track or collect information about individuals without their knowledge and consent

4.3 Third-Party Privacy Rights

You have obtained explicit consent from individuals (or their legal guardians for minors) before uploading their photos or personal information
You will not upload photos of individuals who have explicitly refused or withdrawn consent
You will immediately remove any content upon request from the individual depicted

4.4 Indemnification for User Content

You agree to indemnify, defend, and hold harmless Face Minds and its affiliates from any claims, damages, losses, or legal fees arising from your violation of any person's privacy rights or uploading content without proper authorization.

5. Data Sharing

We do NOT sell your personal data. We may share data only with your consent, with service providers (cloud storage, RevenueCat, Google AdMob for free tier, analytics), or when required by law.

5.1 Advertising Partners

For users on the Free tier, we use Google AdMob to display advertisements. Memories and Archive subscribers do not see ads and their data is not shared with advertising partners.

6. Your Rights and Choices

Access: Request a copy of your personal data
Correction: Update or correct inaccurate information
Deletion: Request deletion of your account and associated data
Data Export: Download your family tree data in a portable format
Opt-out: Disable certain features like face recognition
Ad Preferences: Opt-out of personalized advertising through device settings

7. Children's Privacy

Our app is designed for family use. We do not knowingly collect personal information from children under 13 without parental consent.

8. Third-Party Services

RevenueCat: For managing subscription payments. See RevenueCat's privacy policy.
Google AdMob: For displaying advertisements in the Free tier. See Google's privacy policy.

9. International Data Transfers

Your data may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers.

10. Data Retention

We retain your data for as long as your account is active. When you delete your account, personal data is deleted within 30 days. Some data may be retained for legal purposes for up to 90 days.

11. Changes to This Privacy Policy

We may update this privacy policy from time to time. We will notify you of significant changes through in-app notifications, email, or an updated "Last Updated" date.

12. Contact Us

If you have questions about this privacy policy, contact BynarTek:
Email: faceminds@bynartek.com

13. Your Consent

By using our app, you consent to this privacy policy. By uploading photos or personal information of other individuals to Face Minds, you confirm that you have obtained their explicit consent and accept full responsibility for any legal consequences.

GDPR Compliance (EU Users)

Right to data portability
Right to object to processing
Right to restrict processing
Right to lodge a complaint with supervisory authority

CCPA Compliance (California Users)

Right to know what personal information is collected
Right to know if personal information is sold or disclosed
Right to opt-out of sale of personal information
Right to non-discrimination for exercising CCPA rights

Vietnam PDPL Compliance (Vietnamese Users)

Biometric Data Processing

Explicit Consent Required: We obtain explicit, voluntary, specific consent before processing any biometric data
Purpose Limitation: Your biometric data is processed solely for the purposes stated at the time of consent
Right to Withdraw: You may withdraw your consent at any time through app settings

Data Security & Breach Notification

Biometric data is encrypted using AES-256 encryption
In case of a data breach, we will notify you within 72 hours and report to the Ministry of Public Security as required by law

Contact for Data Protection (PDPL): faceminds@bynartek.com